Article | 2025 year-end tax planning
2025 Year-end planning considerations for key business-related tax provisions in the OBBBA
Nov. 12, 2025 · Authored by Paul Dillon
Signed into law on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) (P.L. 119-21) brought forth numerous tax changes, including business, international and individual tax provisions, among others.
The tax provisions include the extension and permanency of many Tax Cuts and Jobs Act (TCJA) provisions previously scheduled to sunset, enhanced business tax breaks, limitations on individual and business deductions, and significant changes to international tax provisions, all of which have varying effective dates and expiration dates.
Below is an overview of key business-related provisions included in the OBBBA and considerations for year-end tax planning.
Full expensing of qualified property
This provision permanently reinstates 100% bonus depreciation for the cost of qualified property acquired on or after Jan. 20, 2025.
Planning considerations:
- Qualified Property is tangible personal property with a recovery period of 20 years or less; this includes qualified improvement property (QIP) for real estate purposes.
- This provision significantly improves the benefits of cost segregation studies for real estate.
- For purposes of determining the acquisition date, property is not considered to be acquired after the date on which a written binding contract has been entered into to acquire the property.
- Caution: Assets placed in service before Jan. 20, 2025, will only be eligible for 40% bonus depreciation.
- Caution: There are restrictions on depreciation for property used outside the United States, property financed by tax-exempt bonds, and property leased to or used by tax-exempt entities, which would prohibit the use of the 100% bonus provision. If these situations apply, you should contact your Baker Tilly advisor for additional information.
